Maintenance of vehicles Organization and control in EU ...
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Maintenance of vehicles Organization and control in EU legal system Nathalie Duquenne, ERA Safety Unit Training in Budapest 29th June 2017
Transcript of Maintenance of vehicles Organization and control in EU ...
Maintenance of vehiclesOrganization and control in EU legal system
Nathalie Duquenne, ERA Safety Unit
Training in Budapest
29th June 2017
Content
Slide 2
• Overall framework
• Maintenance management functions
• Allocation of responsibilities
• Interface between ECM Regulation and TSIs
• Change of ECM
• Substitution in the framework of maintenance
• Status of ECM implementation
* Maintenance includes repairs (hereafter the term « maintenance » is used)
OVERALL FRAMEWORK
The legal environment
Supplier ECM
IM
RU KEEPER KEEPER
STI conformity
EC declaration
ECM certificate
workshop certificate
Safety certificate
Safety authorisation
Wagon is a shared resource in the open access system
Key railway actors
CUSTOMER
ECM
IM RUTrack
Access
SafetyCertification
TransportContract
MaintenanceContract
Renting Contract
Contract of use - GCU KEEPER
ECM CERTIFICATIONBODYNSA
Surveillance of MSSupervision of SMS
ECM CERTIFICATIONBODY
NSA
Certification of MSCertification of SMS
Railway Safety Directive 2004/49 (Article 14a)
• All vehicles registered in the NVR must have an ECM
• Each ECM shall have Maintenance System
• ECM holds overall responsibility for maintenance
• Without prejudice to respective roles of other parties
• For example RU/IM keeps the responsibility to define criteriato select the ECM
Legal framework of ECM certificationGeneral requirements for ECM
Slide 6
Exceptions for 1520 mm track gauge
Slide 7
Railway Safety Directive
EU Member States can derogate from EU system to identify ECM in respect of:
- Vehicles registered in a third country and maintained according to the law of that country
- Freight and passenger coaches in shared use with third countries
- Any other vehicles for which international agreements with third countries fulfill equivalent objectives (compliance with relevant maintenance requirements, maintenance file and traceability)
Mandatory certification for ECM for freight wagons
• Regulation 445/2011 and its sectorial accreditation scheme
• COTIF ATMF annex A = identical rules for OTIF
• ECM maintenance system is certified by certifaction body
Voluntary certification for workshops
• Regulation 445/2011 applies as good practice
• National rules shall be avoided in this field
Non-certified ECM for other vehicles (attestation of conformity)
• Maintenance system of RU and IM is assessed during the assessment of the SMS
Legal framework o ECM certificationSpecific requirements for ECM
Cooperation of certification bodies
Slide 8
MAINTENANCE MANAGEMENT FUNCTIONS
ECM introduction
The resources required to control risks related to themaintenance process can be excessive for newcomers or smallrailway operators.
To support the opening of the market, after consultation withthe sector, it has been decided to define a new entityresponsible to ensure, by means of a system of maintenance.
Specific Elements
Generic Elements
Risk assessment
SMS : safety and monitoring
SMS requirements for Maintenance:Policy, roles & responsibilities, design of the
process, competence management, technicalprocedures & instructions, maintenance file of
each vehicle, monitoring procedures, contracts’ definition …
Slide 10
Establish the maintenance
file
Remove from operation and
return to operation
Deliver the technical
maintenance tasks
MANAGEMENT PROCESS-ECM
MANAGEMENT PROCESS MANAGEMENT PROCESS MANAGEMENT PROCESS
Scope of ECM certification Maintenance system
Today Regulation 445/2011Amended Railway Safety Directive 2016/798 article 14
Maintenance delivery
Fleet maintenance management
Maintenance development
Maintenance management – no outsourcing
Maintenance System Functions
Can be outsourced
Maintenance Development
Fleet Maintenance Management
Maintenance Delivery
• Records on Maintenance performed
• Return on experience
Return/Remove to/from OperationsTo RUs, IMs, keepers
• Records on Maintenance performed
• Release to service
• Return on experience
Vehicle to maintain Maintained vehicle
Information on OperationsTo RUs, IMs, keepers
Maintenance file
MaintenanceOrders
Performance targets
Initial Technical Documentation
Technological Survey
Legislation
ECM
Man
age
me
nt
The Maintenance Maintenance System
Slide 13
Certification of ECMs and Maintenance Workshops
The process for certification and surveillance is similar to ISO 9001, 14001
Requirements are specific in Regulation 445/2011 ( Annex 3)
Three ways to appoint the ECM Certification Body:
- Accreditation (privileged by EU law to achieve trust)
- Recognition
- Designation by the Member State ( NSA acts as certification body)
Slide 14
The 1st wagon derailed
(type: Eaos, EVN n° 31815341854-2)
Keeper:
Company A
ECM:
Company B in the same country
Example : Derailment in Bressanone
Both wheels (monoblock) of the 1st axle and one wheel (monoblock) of the 4th axle displaced.
Example : Derailment in Bressanone
Accidental displacement of the wheels
Information exchange and transmission of documents between “maintenancedevelopment function” and “maintenance delivery function” was not good
The activity of internal control of ECM, in particular concerning the “maintenancedelivery function” (priority in the case this function is external), should be improved
Regulation 445/2011 requires ECM to react in right way and exchange informationafter an incident where the lack in the maintenance process is evident (importantsurveillance by the ECM Certification Body)
For the wheels of the first wheelset, the value of interference was also smaller than the prescription of the ECM (limit value in rules)
Main feedback from the incident
ALLOCATION OF RESPONSIBILITIES
Some business models
RUs Keeper ECM
Contract
of useContract of
Maintenance
Slide 19
Internal ECM
RU KeeperContract of use
Contract of Maintenance
Some business models
Slide 20
RUKeeper
=ECMContract of use
Some business models
Slide 21
ECM
Maintenance is under the responsibility of ECM
Design
operating
state USE Degradation of performance
Maintenance
ECM
Slide 22
ECM
Railway Safety Directive 2004/49“To this end, the ECM shall ensure that vehicles are maintained in
accordance with:
a)the maintenance file of each vehicle;
b)the requirements in force including maintenance rules and TSI provisions.
The ECM shall carry out the maintenance itself or make use of contracted maintenance workshops.”
• ECM must set up and keep updated the maintenance file (maintenance development);
• ECM must ensure that the maintenance file is effectively applied (fleet management and delivery);
• ECM must coordinate all those activities and supervise its subcontractors.
Slide 23
ECM
Regulation 445/2011
Exchange of information:
The ECM has to address return to operation issues to RUs and keepers.
Certification for FREIGHT WAGONS:
• The ECM must be certified against the Regulation 445/2011;
• The ECM must inform its partners, RUs, IMs and Keepers, about all changes related to its certification, e.g. amendment, renewal, suspension, revocation.
Slide 24
Railway Undertaking
Design operating
state USE Degradation of performance
Maintenance
ECM
RU
Slide 25
Railway Undertaking
Railway Safety Directive
“RU shall be made responsible for safe operation and associated control of risks.”
“Through its SMS, the RU shall control all risks associated with its activitiesincluding supply of maintenance and use of contractors.”
• ECM certification provides assurance to RU that ECM is competent to address the risks associated to supply of maintenance
• Regulation 445/2011 imposes to RU to ensure that the ECM is registered in the NVR and appropriately certified
Slide 26
ECM
cer
tifi
cate
ass
ure
s th
ese
two
req
uir
emen
ts
are
met
Define what you need to control your risks and include it clearly in the contract
(Supported by Risk Assessment)
Check that the contractor is organised to deliver what you want
Check contractor is competent to deliver what you want
Monitor that the contractor is delivering what you want
(Supported by Risk Assessment)
RU
/ IM
RU
/IM
RU
/IM
Railway Undertaking / Contracts
Slide 27
Railway Undertaking
Design operating
state USE
Degradation of performance
Maintenance
ECM
RU
SMS control measures
1. Certification is not a full guarantee of absence of errors;
2. Between maintenance interventions, risks of degradation of performance.
Example of Risks to be controlled trough the
Safety Management System
e.g. pre-departure checks, restrictions in operations, etc.
Slide 28
Example : Derailment at Artenay (1)
The surface damages should have been detected and measures should have been taken at least on the following occasions :
• Feb 2002, wheels reprofiling at workshop X;
• Oct 2002, wheelset overhaul at workshop X;
• July 2004, wheels reprofiling at workshop X;
• Feb 2008, on pit examination during wagon overhaul at workshop Y.
The 9th march 2011, the 17th and 19th wagon of the freight train n°62858 derail in open track on the 4 track electrified line between Paris and Orleans, before the station of Artenay.
• The 17th wagon has its first 3 axles derailed. The first wheelset axle is broken in two parts.
Example : Derailment at Artenay (2)
SMS of RURisk Control Measures such as pre-departure and en route inspections, restriction in operations.
Relevant?
“The Safety Management System shall also take into account, where appropriate and reasonable, the risks arising as a result of activities by other parties”
Safety Directive 2004/49
Appropriate? Reasonable?
Keeper
Design operating
state USE Degradation of performance
Maintenance
ECM
KEEPERRU
Slide 31
Keeper
‘Keeper’ means “the person or entity that, being the owner of a vehicle or having the right to use it, exploits the vehicle as a means of transport and is registered as such in the National Vehicle Register (NVR) provided for in Article 33 of Interoperability Directive 2008/57/EC.”
Safety Directive 2004/49
According to NVR legal rules, the keeper is the registration holder in the sense of article 33 of Interoperability Directive 2008/57 (if not otherwise mentioned).
Slide 32
Keeper
The keeper has contracts with ECM and RU
The keeper is responsible for all its allocated contractual tasks
RUs Keeper ECMContract of use Contract
Contractual tasks may be related to exchange of information between RU and ECM (keeper = intermediate)
The keeper is also responsible to the RU to provide vehicles in conformity with the legislation:
Vehicles with a valid authorisation for placing in service
Freight wagons with ECM duly certified
Slide 33
The exchange of informationIt is an important requirement taken in account in the ECM Regulation for the 3 parts: RUs, keepers and ECMs.
Some references and means• TSI Telematic Application for Freight (TAF TSI), in order to harmonise all
the information systems related to the transport of freight wagons;
• Private initiative: e.g. UIP, is developing a Rolling Stock reference Database (RSRD²) in order to respond to the TAF TSI requirements;
• Database ERADIS;
• NVR.
Exchange of information
INTERFACE BETWEEN ECM REGULATION AND TSIs
APS
Context
Initial technical documentation including
the technical file
Design
operating
state USE Degradation of performance
Maintenance
Maintenance file
*APS = Autorisation for placing into serviceSlide 36
Maintenance development process (I)
Process of establishment of the first maintenance file
Process of continuous update/improvement of the maintenance file
INPUT Maintenance development
OUTPUT
Maintenance file Technical file Information on operation Records on maintenance
performed and return on experience
Technological survey Legislation (changes) Performance targets
Maintenance file updated
INPUT Maintenance development
OUTPUT
Technical file Information on operation
planned to be performed Performance targets
(First) Maintenance file
Slide 37
Collection of information
Analysis of information
Design of the change in the
maintenance file
Implementation of the change
Dissemination of the change
Maintenance File Updated
Maintenance development process (II)
Continuous update/improvement of the maintenance file by applying CSM on Monitoring
CSM for Risk Assessment
CHANGE MANAGEMENTChange of ECM
Regulation 445/2011
“When there is a change of ECM, the registration holder … shall inform in due time the registration entity… so that the latter may update the National Vehicle Register.
The former ECM shall deliver the maintenance documentation to either theregistration holder or the new ECM.
The former ECM is relieved of its responsibilities when it is removed from theNational Vehicle Register. If on the date of de-registration of the former ECMany new entity has not acknowledged its acceptance of ECM status, theregistration of the vehicle is suspended.”
Slide 40
• The change may be motivated:
For business purposes
Bankruptcy
By revocation/suspension of ECM certificate
• Minimum information to be transferred to the new ECM:
(sufficient) information on the maintenance file including records on maintenance performed
The technical documentation (technical file is not the property of ECM)
The configuration files of each vehicle
All additional information required by the contract between keeper and ‘former’ ECM
Slide 41
The are risks arising from the interface with ECMs
EXAMPLE:Maintenance file is strongly associated to the “know-how” of the ECM.
Stakeholders (incl. the keepers) should control this risk in its contracts with the ECM.
Slide 42
CHANGE MANAGEMENTSubstitution in the framework of maintenance
ECM is responsible: “to manage the substitutions in the framework of maintenance.“ Regulation 445/2011
Note: Vehicles in service may be TSI compliant or not.
Substitution in the framework of maintenance means:
“any replacement of components by parts of identical function and performance in the framework of preventive or corrective maintenance” Interoperability Directive 2008/57
Two types of parts: Parts with references in the technical file
Parts with (appropriate and sufficient) specifications in the technical file
Slide 44
ECM responsible for: “verifying in all circumstances the consistency of the maintenance file with the authorisation of placing-in-service”. Regulation 445/2011
Note: Vehicles in service may be TSI compliant or not.
Then the role of ECM is to verify that the vehicle is maintained in accordance with the design operating state, with the parts mentioned in the technical file, also when proceeding with substitutions!
Slide 45
Substitutions in the field of maintenance do not affect the technical file of the vehicle and therefore remain within the scope of the authorisation of the vehicle.
Not considered as a renewal or upgrading requiring new authorisation for placing into service.
Slide 46
The majority of vehicles in service are not TSI compliant or have never been verified against TSIs:
NO authorisation and technical file in conformity with Interoperability Directive 2008/57 and TSIs.
BUT
for each of those vehicles, there is an approved design against previous national rules with a documentation similar to the (TSI).
Slide 47
STATUS OF ECM IMPLEMENTATION
ECMs in ERADIS database 2016
49
Certified maintenance workshops 2016
50
Many thanks for your
attention!
Contact:
Nathalie.Duquenne
@era.europa.eu
